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    <title>1963 (11) TMI 100 - MADRAS HIGH COURT</title>
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    <description>Reassessment under section 34(1)(a) was treated as invalid where the assessee had already disclosed the primary facts, including the relevant agreements and accounts, before the original assessing officer. The materials on record were sufficient for the officer to assess the receipts, and a later attempt to reopen on the same facts amounted to a mere change of opinion rather than a failure of full and true disclosure. Although reassessment is not confined to the exact items mentioned in the notice, additions could not stand once reopening itself lacked jurisdiction.</description>
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      <link>https://www.taxtmi.com/caselaws?id=285493</link>
      <description>Reassessment under section 34(1)(a) was treated as invalid where the assessee had already disclosed the primary facts, including the relevant agreements and accounts, before the original assessing officer. The materials on record were sufficient for the officer to assess the receipts, and a later attempt to reopen on the same facts amounted to a mere change of opinion rather than a failure of full and true disclosure. Although reassessment is not confined to the exact items mentioned in the notice, additions could not stand once reopening itself lacked jurisdiction.</description>
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      <pubDate>Wed, 06 Nov 1963 00:00:00 +0530</pubDate>
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